Corrective Action Plans

The District will review the requirements of 2 CFR Section 200.214 and 2 CFR Part 180 and ensure that a review of the eligibility of potential vendors to participate in Federal assistance programs or activities is performed prior to disbursing funds to the vendor. This will be verified on an annual basis. Anticipated implementation date is October 1, 2025 by responsible person(s) District Business Official and District Treasurer Kelsey Reed.

CORRECTIVE ACTION PLAN Finding 2025-001 – Reporting The District concurs with the finding 2025-001. Corrective Action: Moving forward, the District Treasurer will enter the monthly claims with the Food Service Director and will verify that the meal counts and the total claims are correct for both breakfast and lunch. The anticipated completion date of the corrective action is September 29, 2025. Contact Person: Alicia D. Koster, Superintendent of Schools (518) 762-4611 akoster@johnstownschools.org

Finding 2024-001 – Child Nutrition Cluster Condition: Year-end financial reports contained errors related to the recording of receipts and expenditures for the major federal programs. Cause: The District did not have sufficient monitoring procedures in place to ensure accurate and timely review of federal program financial activity. Corrective Action Plan: The District has taken and will continue to take the following corrective actions to address the identified weaknesses: 1. The District has hired and assigned staff with primary responsibility for federal grant management and compliance oversight. 2. Key personnel involved in federal program administration and accounting have received training related to federal grant requirements, internal controls, and monitoring procedures. 3. The District has implemented enhanced internal review procedures, including periodic reconciliation and supervisory review of federal program receipts and expenditures throughout the fiscal year. 4. Management will conduct ongoing monitoring of federal programs to ensure that financial activity is accurately recorded and reviewed prior to year-end reporting. 5. The District will continue to evaluate internal controls annually and adjust procedures as needed to maintain compliance with Uniform Guidance requirements.

2024-012 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: Based on the Commonwealth of Pennsylvania, Office of the Budget, Bureau of Audits (Commonwealth) review of CBS Food Program's financial accounting system, it was noted that the Food Program utilizes QuickBooks software for their accounting system. Based on inquiry with CBS Food Program management, we determined internal controls connected with their QuickBooks accounting software were insufficient in the following areas: • User Access Management: Formal written policies or procedures have not been developed and implemented related to access authorization, access monitoring, and removal of system access. Additionally, certain functions are not properly segregated as users have access to perform both input and authorization of transactions. • Input Management: Formal written policies or procedures to ensure information input into QuickBooks is appropriate and accurate have not been developed and implemented. • Change Control Management: A formal written change management policy for QuickBooks Accounting System has not been developed and implemented including requirements that system security updates are implemented timely. • Backup and Recovery: A formal written policy for regular backup and recovery testing has not been developed and implemented. Recommendation: We recommend that CBS Food Program develop and implement comprehensive written internal control policies and procedures connected with their QuickBooks Accounting System. This should include: • Development and utilization of an Accounting Manual which includes an outline of CBS Food Program's accounting rules, procedures, and guidelines. • Access control policies and procedures to ensure that user access to QuickBooks is appropriate, regularly reviewed and promptly revoked upon termination or when otherwise merited. Recommendation (Continued) • A formal written change management policy for QuickBooks should be developed and implemented including requirements that systems security updates are implemented timely. • A disaster recovery plan and procedures to perform periodic testing to ensure that plans are functional and mitigate the risk of extended downtime. This process should also include regular review of backup records to ensure they are appropriately created and maintained. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions does not dispute this finding. Community Benefit Solutions will migrate from Quickbooks Desktop to Quickbooks Online, which will provide a perfect transitional opportunity to re-evaluate processes, and to develop and implement necessary controls over its systems. Community Benefit Solutions will work with independent auditors, internal information technology team, and, if necessary, legal counsel to plan, draft, and implement the relevant internal controls. Planned completion date for corrective action plan: June 30, 2025

2024-011 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: Based on the Commonwealth of Pennsylvania, Office of the Budget, Bureau of Audits (Commonwealth) review of CBS Food Programs banking policies, it was noted that the CBS Food Program did not establish appropriate controls to ensure bank account access changes and bank account closures could be promptly completed when organizational or personnel changes merited such actions. CBS Food Program management noted two instances during the engagement period in which lack of cooperation from parties with CBS Food Program bank account authority or access prevented the Food Program from closing bank accounts in an expeditious manner. This resulted in the CBS Food Program simultaneously having bank accounts open at three different banks for a portion of the audit period. As of May 2025, CBS Food Program only actively banks with one institution. Of the accounts with the other institutions, one account is closed, and the other remains open, but inactive because CBS Food Program has not initiated any account-related activity for an extended period of time. According to CBS Food Program management, they are working to close the inactive account, but closure requires assistance from Congregation Beth Solomon which has not been cooperative. The Commonwealth noted that CBS Food Program has inefficient control procedures in place over the issuance of high-value checks. Following the separation of CBS Food Program's prior CEO, the Food Program opened a new bank account in order to remove the prior CEO's access to food program funds. The former CEO was not cooperative in removing his access to the bank account the Food Program used at the time of his separation, so CBS Food Program determined moving the Food Program's funds to a new bank was in the best interest of the organization. To move the Food Program's funds from the old bank to the new bank, CBS Food Program's Director of Finance wrote two checks for $1.5 million dollars each. While CBS Food Program's Director of Finance obtained approval from the board prior to preparing and depositing the checks in the new bank account, a secondary signature was not obtained as CBS Food Program policy did not require a second signature for any check regardless of amount. Recommendation: CBS Food Program should assign bank authorization and access roles to appropriate CBS representatives to ensure access is appropriately limited, but that changes to account authorization can be completed timely when organizational or personnel changes merit such modifications. CBS Food Program should establish, document, and adhere to, a policy requiring documented prior approval and dual signatures on checks exceeding a predetermined threshold set by management and/or the board of directors. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Planned completion date for corrective action plan: June 30, 2025 Action taken in response to finding: Community Benefit Solutions does not dispute this finding and provides the following for the purpose of additional clarification. Between February 14, 2024, and June 10, 2024, the departure of the Farmer CEO and several key Board members resulted in the absence of authorized signers. In order to expeditiously remove individuals from accessing bank funds during this transition, the Community Benefit Solutions Board of Directors granted the Accounting Associate authority to sign all relevant checks and take steps necessary to remove those individuals. Going forward, Community Benefit Solutions will, with the assistance of either Board-approved counsel or outside independent audit firm, develop and implement thresholds for dual signature requirements. Moreover, Community Benefit Solutions will work with JP Morgan Chase Bank to ensure that authorization and authority can be expeditiously amended in the event such a need arises.

2024-010 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: Based on interviews by the Commonwealth of Pennsylvania, Office of the Budget, Bureau of Audits (“Commonwealth”) with CBS Food program management, inspection of records, and on-site observations, we identified internal control deficiencies in the following areas: • For a portion of the audit period, there was a lack of segregation of duties between the cash receipt, bookkeeping, and bank reconciliation processes. The Director of Finance was responsible for all these tasks. The Director of Finance was also responsible for both processing and approving payroll and had authorization to make purchases, make vendor payments, record accounting transactions and complete bank reconciliations. • CBS Food Program performs bank reconciliations; however, they are not signed or dated by the individual performing the reconciliation and a second individual does not review or sign off on the reconciliations. Of nine reviewed account reconciliations, three were completed more than 30 days after the statement period end date. • According to CBS Food Program's former Purchasing Distribution Manager, as of June 2024, they were the only CBS Food Program's employees with detailed knowledge of developing monthly menus and creating purchase orders based on current inventory levels to meet menu requirements. Additionally, the former Purchasing Distribution Manager stated that as of June 2024 formal training on internal purchasing policies and procedures is not provided or required. Condition (Continued) • For a portion of the engagement period, CBS Food Program lacked written policies or procedures for several key business functions including: o No written Accounting Manual or Standard Operating Manual for accounting functions. o No written policy or procedure for the use of credit cards or the handling of lost or stolen credit cards. o No written policy or procedure to analyze account balances to ensure transactions have been properly recorded. o No written records retention policy. o No written procedures for handling payroll for separating employees. o No written or implemented review process for changes to the payroll system including changes to employee payrates. o For a portion of the engagement period, the Food Program did not have procedures to o Prior to July 1, 2024, CBS Food Program did not have documented procurement procedures. On July 1, 2024, CBS Food Program implemented a procurement plan. Recommendation: If not already addressed, CBS Food Program should develop and implement improved internal controls including: • Develop written policies, procedures and/or manuals for accounting functions. • Develop a formal internal control policy and framework that focuses on key business and operations areas including segregation of duties, transaction review and approval processes, and monitoring procedures over critical operational functions. • Improve cross training of employees including training on purchasing and accounting tasks. • CBS Food Program should develop and implement a record retention policy that complies with food program requirements for maintaining documentation of operations. The policy should ensure key records are maintained in a shared location accessible to all appropriate personnel. This ensures the CBS Food Program does not lose access to key records in the event an employee leaves the food program. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions will work with its outside independent audit firm, Board-approved counsel, and other necessary stakeholders to develop and implement all the necessary controls as required by the Comptroller. Community Benefit Solutions' implementation of any of the noted changes will be the ability to recruit Finance Committee and Nutrition Committee members of the Board. Moreover, Community Benefit Solutions made strides in implementing some of the requested policies during the Audit. Community Benefit Solutions will endeavor to meet each of the requests despite any lack of human capital that would allow for ease of segregation of authority. Community Benefit Solutions is optimistic that incoming Board Members and external accounting, audit, HR, and legal will provide critical support. Planned completion date for corrective action plan: June 30, 2025

2024-009 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: Based on Commonwealth of Pennsylvania, Office of the Budget, Bureau of Audits (Commonwealth), testing and calculations of the CBS Food Program's Net Cash Resources Available and their 3 months averages expenditures, the Commonwealth determined the Food Program's net cash resources exceeded their 3 months average expenditures as of June 30, 2024. The Commonwealth calculated both 3-month average operating expenditures and Net Cash Resources Available based on financial statement information provided by CBS Food Program. The Commonwealth's calculations of Net Cash Resources found that the Food Program exceeded their 3 months average expenditures by $2,354,119 as of June 30, 2024. The Pennsylvania Department of Education (PDE) has been communicating with CBS Food Program to develop plans for spending down their excess non-profit food program balance. Recommendation: CBS Food Program should work with PDE to develop a plan to appropriately utilize its resources. In the future, the Food Program should monitor cash resources to ensure they do not exceed maximum thresholds required by federal regulations. Excess food program resources can be used to improve or expand the nonprofit food service for program participants. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions agrees in principle with this finding; however, disputes the amount of Net Cash Resources Available in Excess of Federal Regulation. Based on the 2025 Year End Balance, CBS Food Program has $1,087,495.35 in cash and $2,106,728.79 in Certificates of Deposits which totals $3,194,224.11 in Net Cash Resources. CBS Food Program's expenditures during the 24-25 Program Year totaled $8,542,614, which results in allowable Net Cash Resources of$2,135,653.50 (three months of total expenditures). More accurately, the expected expenditures for the 25-26 Program Year are $7,167,206, results in allowable Net Cash Resources of $1,791,801.50. Accordingly, Community Benefit Solutions contends that the Net Cash Resources Available in Excess of Federal Regulations is $1,793,571. Prior to the issuance of the Draft Report, Community Benefit Solutions provided PDE with a preliminary Spend Down Proposal based on an expected $2,800,000 in excess funds. The Spend Down Proposal included, among other things, $837,000 set aside for the purpose of equipping Community Benefit Solutions' new headquarters with a commercial kitchen, refrigerator, and freezer (the "Warehouse Buildout"). PDE approved the portion of the Spend Down Plan pertaining to the Warehouse Buildout. The Board of Directors along with Community Benefit Solutions leadership and PDE will continue to coordinate and determine appropriate and allowable actions to spend down Net Cash Resources in accordance with the federal requirements. Planned completion date for corrective action plan: June 30, 2025

2024-007 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: During our testing of subrecipient monitoring activities for PDE programs CACFP, NLSP, and SFSP, we selected 31 contracted centers at random. Management provided documentation for each site, including contracts, meal pattern usage records, licensure and training documentation, and both announced and unannounced meal observation reviews. However, we found that CBS Food Program did not always maintain sufficient evidence to prove required monitoring was performed under the CACFP program. For one center, management could not produce proof that meal observation reviews or the mandated two unannounced visits occurred. At another center, neither a contract nor any meal observation review records, including the two required unannounced visits, could be provided. For the NLSP and SFSP, management was unable to provide contracts for any of the seven sampled centers. Additionally, there was no evidence of training for one center, and a second center had a noncompliant monitoring visit; although corrective action was prepared, follow-up occurred only after 66 days instead of within the required 45-day window. Recommendation: We recommend that management strengthen internal controls to ensure all required PDE CACFP, NLSP and SFSP subrecipient monitoring activities, including scheduled meal observations and the mandated unannounced visits—are consistently performed, documented, and retained. Management should implement a centralized tracking system to monitor review deadlines, required follow up actions, and receipt of supporting documentation from each contracted center. In addition, staff responsible for monitoring should receive periodic refresher training on PDE CACFP, NLSP and SFSP specific expectations. Finally, management should conduct periodic internal reviews to verify that monitoring documentation is complete, compliant, and appropriately maintained. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions shall utilize internally developed Quickbase application to schedule and track monitoring visits including ensuring necessary corrective action follow-ups are conducted within 45 days documented corrective action needed. Moreover, Community Benefit Solutions will require all monitoring staff to successfully complete monitoring specific training in addition to the annual and civil rights training to ensure up to date knowledge of all requirements. Trainings will be assigned, monitored and signed off on by Director of Operations. Planned completion date for corrective action plan: June 30, 2025

2024-006 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: As part of our procurement testing in accordance with Uniform Guidance requirements, we requested that management provide the most recent suspension and debarment assessments for the vendors selected for review. Our analysis indicated that management did not perform these assessments by reviewing the federal government's suspended or debarred vendor list on SAM.gov. Rather, they relied on vendor certifications obtained through the Commonwealth of Pennsylvania, Department of Education, to determine vendor eligibility with respect to suspension or debarment from federally funded programs. Additionally, we observed that the current procurement policy for the CBS Food Program does not outline a formal procedure for evaluating vendors' suspension and debarment status as required by Uniform Guidance. Recommendation: We recommend that management establish and implement a formal process for evaluating vendors regarding suspension and debarment. This process should include regular reviews of the federal government's suspended or debarred list on SAM.gov to ensure that vendors are not suspended or debarred from participating in federal programs. Additionally, management should ensure that all procurement policies and procedures are updated to reflect this requirement. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions shall update its current procurement policy to include a suspension and debarment review of all vendors seeking to do business with the organization. Prior to February 13, 2026, Community Benefit Solutions shall conduct a comprehensive review of all current vendors to ensure compliance with these recommendations. Community Benefit Solutions will update procurement policy to include quarterly suspension and debarment review to be conducted by Quality Assurance Associate and signed off on by Warehouse and Purchasing Director. Planned completion date for corrective action plan: June 30, 2025

2024-004 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition As part of our audit procedures, we selected a sample of 40 payroll transactions for review. This process included examination of employee human resource files (such as signed W-4 and I-9 forms), management-approved pay rates, time sheets with supervisory sign-off, and corresponding payroll reports. We recalculated total hours per timesheet using the employees' pay rates and compared these figures to the relevant payroll reports. During our review, we observed that two employees received additional compensation ranging from $25 to $75 for undertaking extra responsibilities related to the administration of the CBS Food Program’s Summer Food Service Program by the former Chief Executive Officer. Management was unable to provide supporting documentation evidencing approval by the former Chief Executive Officer or confirmation from the Commonwealth of Pennsylvania, Department of Education, indicating that such additional compensation complied with the contractual agreement governing the Summer Food Service Program. Additionally, of the 40 payroll transactions sampled, we noted one employee’s required payroll change documentation (e.g., an approved payroll change form) was not present in their personnel file. Recommendation We recommend that management improve internal controls for payroll authorization by making sure every payroll change form and supplemental compensation approval is filled out, approved, and kept on file. Introducing a central electronic document management system will help securely store records, standardize documentation, and create clear audit trails for all payroll and personnel files. Management should also regularly review payroll records to confirm that all necessary paperwork, such as personnel forms, pay rate approvals, and backup for extra pay, is included. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions repeats the actions to be taken in response to finding 2024-003 and adds the following: Community Benefit Solutions will utilize ADP document management capabilities to maintain employee files including, but not limited to, Payroll Change Forms or other documentation related to modifications or supplements to employee pay. Community Benefit Solutions will ensure complete upload of all paper files to the appropriate employee profile within ADP to ensure documentation can be readily accessible by those with necessary authorization. Planned completion date for corrective action plan: June 30, 2025

2024-008 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: As part of the reporting requirements for the CBS Food Program under the National School Lunch Program (NSLP) and Summer Food Service Program (SFSP), management is responsible for submitting the FNS 10 (NSLP) and FNS 418 (SFSP) reports within 30 days after month-end. However, management was unable to provide five (5) monthly NSLP reports and one (1) monthly SFSP report requested for audit testing. Recommendation: The Organization should establish and enforce strengthened internal controls over federal reporting to ensure that all required monthly reports (FNS 10 and FNS 418) are: (a) completed accurately, (b) submitted on time, and (c) retained in accordance with federal record retention requirements (2 CFR 200.334). Management should designate responsible personnel and implement a monitoring process to ensure compliance. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Effective, July 1, 2024, Community Benefit Solutions no longer administers the National School Lunch Program. In the event Community Benefit Solutions should begin administering the NSLP, Community Benefit Solutions will develop and implement requisite policies and procedures to ensure proper reporting requirements including, but not limited to, completion and submission of the FNS10. Planned completion date for corrective action plan: June 30, 2025

FA-2024-003 Strengthen Controls over Expenditures Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: AL Numbers and Title: Federal Award Number: Questioned Costs: Activities Allowed or Unallowed Allowable Cost/Cost Principles Significant Deficiency Nonmaterial Noncompliance U.S. Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19-10.555 - National School Lunch Program 245GA324N1199 (Year: 2024), 225GA324N1099 (Year:2024) $2,641.33 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating to ensure that expenditures were appropriately reviewed, approved, and documented. Corrective Action Plan: A bookkeeper has been hired for the School Nutrition Program. Bookkeeper keeps alphabetical organized files for each vendor to monitor and track revenue and expenditures. The bookkeeper prepares voucher packets for payments and credits for each vendor on a monthly basis. The bookkeeper signs the voucher package for accuracy. The Nutrition Director signs the voucher package for accuracy. Records are maintained under lock and key for a period of five years. Estimated Completion Date: July 1, 2025 Contact Person: Danny Durham, Director of School Nutrition Telephone:478-994-2031 Email: danny.durham@mcschools.org Title: Director of Financial Services

FA 2024-002 Strengthen Controls over Journal Entries Compliance Requirement: Activities Allowed or Unallowed Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program COVID-19-10.555 – National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: Unknown Description: The policies and procedures of the School District were insufficient to ensure that journal entries made for the Child Nutrition Cluster were properly documented. Corrective Action Plan: All journal entries transferring cash from the School Nutrition Fund to the General fund will be done on a more frequent basis and include the detail of amounts used to arrive at the amount of the transfer. Estimated Completion Date: October 17, 2025 Contact Person: Danny Durham, Director of School Nutrition Telephone: 478-994-2031 Email: danny.durham@mcschools.org

FA-2024-001 Strengthen Controls over Special Reporting Compliance Requirement: Reporting Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Title: 10.553 – School Breakfast Program 10.555 – National School Lunch Program COVID-19-10.555 – National School Lunch Program Federal Award Number: 245GA324N1199 (Year: 2024), 225GA324N1099 (Year: 2024) Questioned Costs: None Identified Repeat of Prior Year Finding: FA 2023-001, FA 2022-001 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the monthly Claims for Reimbursement process. Corrective Action Plan: Monroe County School Nutrition will print a Meal Participation Report from Primero Edge software for the school district and each school every month. The report mirrors the DE112 and DE118 forms. The software report has been approved by the Georgia Department of Education Area Coach. Breakfast and Lunch totals for each school and district will be entered for claims to complete the DE106 and DE107. Managers will print the Meal Participation Report and verify information is correct by providing a signature on the document. The report is then submitted to the Central Office for review. Edit checks in the software and both will sign off on the Meal Participation Report. Estimated Completion Date: July 1, 2025 Contact Person: Danny Durham, Director of School Nutrition Telephone: 478-994-2031 Email: danny.durham@mcschools.org

FINDING 2024-005 Finding Subject: CHILD NUTRITION CLUSTER - SPECIAL TESTS AND PROVISIONS, PAID LUNCH EQUITY Contact Person Responsible for Corrective Action: BONNIE SANDERS, Director of Food Services Contact Phone Number and Email Address: Sandersb@nlcs.k12.in.us (812) 277-3220 ext. 48014 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Paid Lunch Equity requirements and calculations (including PLE exemptions) will be calculated and completed by the Food Service Director and will then be reviewed and signed off on by the Business Director. Any additional information requested by the Business Director will be provided to the Business Director in a timely manner for use in determining the accuracy and completeness of the PLE document. Anticipated Completion Date: Immediately (December 1, 2025)

FINDING 2024-004 Finding Subject: CHILD NUTRITION CLUSTER - PROCUREMENT, SUSPENSION AND DEBARMENT Contact Person Responsible for Corrective Action: BONNIE SANDERS, Director of Food Services Contact Phone Number and Email Address: Sandersb@nlcs.k12.in.us (812) 277-3220 ext. 48014 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation has a Procurement Plan which includes policies and procedures for procurement and also includes language around suspension and debarment; however, it does not specify purchases or contracts equal to or greater than $25,000. All purchases $25,000 or greater will involve the following process - (1) checking SAM.gov to see if there are any exclusions, (2) require Vendor supply certification that they have not been suspended or debarred OR clause will be added to agreement or contract signed by Vendor as certification. Internal controls will consist of the Food Service Director or other school corporation staff initiating the process and documentation checked by their Supervisor and the Account Payable department. A monetary value will be added to the language in the existing Procurement Plan (policies and procedures) involving the requirement for checking exclusions with SAM.gov and getting certification from the Vendor or contractual agreement with the vendor that they are not suspended or disbarred. Anticipated Completion Date: March 1, 2026 (Procurement Plan revision will need Board approval). Checking SAM.gov and adding clauses to contracts as necessary will begin immediately, December 1, 2025.

FINDING 2024-003 Finding Subject: CHILD NUTRITION CLUSTER - ACTIVITIES ALLOWED OR UNALLOWED, ALLOWABLE COSTS / COST PRINCIPLES Contact Person Responsible for Corrective Action: BONNIE SANDERS, Director of Food Services Contact Phone Number and Email Address: Sandersb@nlcs.k12.in.us (812) 277-3220 ext. 48014 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All payments and expenditures coming out of the Food Service Fund (Fund 800) will be documented and accompanied by supporting additional documents detailing the reason and application of the funding. All payments will be accompanied by vouchers signed by 2 parties (the requestor and their supervisor), as well as an invoice and, if applicable, quote for merchandise or services. In addition, the Accounts Payable staff will also review these documents prior to signature by the Supervisor. Student meal account reimbursements will also be handled in this way, ensuring the appropriate account, Prepaid Food Account (Fund 8400), is the account these funds will be withdrawn from. Stipend requests will be in writing and approved by the Business Director and the School Board prior to being processed by payroll. This will be documented in writing along with any payment documentation. Anticipated Completion Date: Immediately (December 1, 2025)

CHILD NUTRITION CLUSTER – REPORTING U.S. Department of Agriculture Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Passed Through Minnesota Department of Education Pass Through Number: 10.CNC Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend that the district ensures all changes and adjustments are communicated to the accountant who performs claim submissions. When the Nutrition Service Assistant Director’s review results in additional adjustments within PrimeroEdge, the District should only make those changes before the CLiCs cutoff date to prevent differences between client records in PrimeroEdge and CLICS reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on educating all of the personnel involved in the reporting processes to ensure the compliance requirements are fully understood and a proper review of all reporting methods will be performed. This will be implemented by December 31, 2025, and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

CHILD NUTRITION CLUSTER – SUSPENSION AND DEBARMENT U.S. Department of Agriculture Child Nutrition Cluster Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Passed Through Minnesota Department of Education Pass Through Number: 10.CNC Award Period: July 1, 2023 – June 30, 2024 Recommendation: We recommend the District formalizes their suspension & debarment procedures in a policy and ensure they check suspension & debarment for all vendors prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The District will work on educating all of the personnel involved in the procurement processes to ensure the compliance requirements are fully understood and a proper review of all procurements and procurement methods will be performed. This will be implemented by December 31, 2025, and the School Board will be responsible for monitoring the status. Name of the contact person responsible for corrective action: Tom Sager, Executive Chief of Financial Services Planned completion date for corrective action plan: December 31, 2025

Views of Auditee and Corrective Actions: GDOE agrees with the finding. Plan of action and completion date: The Food and Nutrition Services Management Division (FNSMD) will implement an internal calendar reminder to ensure timely notification to School Districts and the annual upload of district-wide eligibility information for the Community Eligibility Provision (CEP) to the FNSMD and GDOE websites. Additionally, FNSMD will implement an internal process to conduct the Direct Certification Matching activity to determine student eligibility for free school meals (Lunch/Breakfast). This process will include matching student data with lists from the Department of Public Health & Social Services (DPHSS) for SNAP (Food Stamps), TANF, FDPIR, Medicaid, Foster Care, Homelessness, or Migrant status. All Direct Certification Matching activities will be completed by April 1st of each year. Plan to monitor and responsible officials: The FNSMD Administrator, Anthony S. Monforte, and FNSMD Program Coordinator, Franklin J. Cruz, will be responsible for implementation and ongoing execution of corrective actions. Corrective actions will be implemented by March 31, 2026.

Effective immediately, Berne Union will require PaySchools to provide its policies and procedures governing the eligibility determination process for free, reduced, and paid meal status. These documents will be reviewed to ensure compliance with federal standards for the Free and Reduced-Price Lunch Program.

FA 2024-001 Improve Controls over Procurement Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: AL Numbers and Titles: Federal Award Numbers: Questioned Costs: Procurement and Suspension and Debarment Material Weakness Material Noncompliance U.S. Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program COVID-19 - 10.555 - National School Lunch Program 10.582 - Fresh Fruit and Vegetable Program 245GA324N1199 (Year: 2024) 245GA324L1603 (Year: 2024) 245GA324l1603 (Year: 2024) $5,380.74 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement procedures were followed. Corrective Action Plans: Implement a standardized procurement checklist that must be completed. Procurements will require two levels of review (program level review by child nutrition staff and District level) to confirm compliance before processing payments. District will provide staff training to ensure federal procurement regulations, district procurement policies along with documentation and recordkeeping requirements are being met. The finance department will conduct quarterly internal reviews of Child Nutrition expenditures to verify compliance. Estimated Completion Date: November 10, 2025 Contact Person: Jon Erik Jones, Superintendent Telephone: 229.321-1487 Email:jones@quitman.ki2.ga.us

VIEWS OF RESPONSIBLE OFFICIALS In response to the finding regarding the untimely submission of the Federal Funding Accountability and Transparency Act (FFATA) reports, the Puerto Rico Department of Education (PRDE) acknowledges the observation made by the auditors. While the audit notes that program staff were unaware of the FFATA reporting requirement, we would like to clarify that the staff was aware of the requirement; however, the program was in the process of gathering the necessary data and ensuring a full understanding of the report components and submission procedures in order to comply accurately with the federal guidelines. Nevertheless, PRDE recognizes that this does not justify the delay in the submission of the reports. To prevent future occurrences, PRDE is currently developing and scheduling a comprehensive training for all program and fiscal staff involved in the Child Nutrition Cluster. This training will cover the FFATA reporting requirements, data collection procedures, submission timelines, and documentation standards to ensure full and timely compliance with the reporting process moving forward. PRDE will continue strengthening internal controls and monitoring procedures to ensure that all applicable FFATA reports are submitted accurately and on time in the FSRS portal. IMPLEMENTATION DATE December 30, 2025 RESPONSIBLE PERSON Odalis Menard AESAN Director Lourdes García Santiago AESAN Sub-Director

VIEWS OF RESPONSIBLE OFFICIALS Management agrees with the audit finding and has implemented a comprehensive corrective action plan to address payroll processing errors, strengthen internal controls, and ensure accurate and timely payments. As part of PRDE’s Fiscal Plan of 2020–2021, the Department launched the official integration project between the Time, Attendance, and Leave (TAL) system and the Payroll (RHUM) system. This integration ensures that payroll disbursements are made only after the employee’s attendance has been validated through the TAL system. Employees are required to record their attendance using biometric verification or have an authorized leave properly documented and approved by their supervisor before receiving payment. If attendance is not validated, the system automatically issues a notification and applies the necessary adjustment. This project, initiated in November 2020 with the collaboration of the Puerto Rico Fiscal Oversight and Management Board (FOMB), MS Consulting, the Department of the Treasury (Hacienda), the Financial Advisory Authority (AAFAF), and the Puerto Rico Innovation and Technology Service (PRITS), was fully integrated by February 2021. As a result, PRDE has significantly reduced overpayments, duplicate payments, and other payroll inconsistencies. To reinforce this effort, PRDE issued a new Time and Attendance Policy on December 7, 2021, later updated on April 11, 2022, which clearly defines employee responsibilities, authorized leaves, disciplinary procedures, and supervisor accountability. Under this policy, employees and supervisors are required to follow strict timekeeping procedures, and noncompliance triggers automatic system notifications and salary adjustments. The PRDE’s Time and Attendance staff continues to monitor and maintain compliance through: i. Ongoing training sessions for PRDE personnel; ii. System dashboards tracking attendance behaviors; iii. Issuance of notifications and payroll adjustments as required; and iv. Regular follow-up and evaluation activities. Additionally, PRDE’s Finance Office implemented a reconciliation process that integrates data from TAL, RHUM, and SIFDE, ensuring that payroll expenditures align with validated attendance records. The system now performs cross-checks before submission to the Treasury Department, preventing disbursements for unverified time. These combined measures—technological integration, policy enforcement, staff training, and reconciliation controls—have strengthened payroll accuracy, reduced the risk of overpayments, and improved financial accountability across the Department. IMPLEMENTATION DATE Done RESPONSIBLE PERSON Evelyn Rodríguez Cardé Finance Office Director Jullymar Octtaviani Vega Sub-Secretary of Administration

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE – U.S. DEPARTMENT OF AGRICULTURE, PASSED THROUGH MINNESOTA DEPARTMENT OF EDUCATION, CHILD NUTRITION CLUSTER – FEDERAL ALN 10.555, 10.559, AND 10.553 2024-006 - Internal Control Over Compliance With Federal Suspension and Debarment Requirements Finding Summary Criteria – 2 CFR § 180 requires the District to establish and maintain effective internal control over compliance with requirements applicable to federal program expenditures, including suspension and debarment requirements applicable to the child nutrition cluster. Condition – The District did not have sufficient controls in place within its child nutrition cluster to assure that it was not contracting for goods or services with parties that are suspended or debarred, or whose principals are suspended or debarred from participating in contracts involving the expenditures of federal program funds. Corrective Action Plan Actions Planned – The District will review its policies and procedures relating to suspension and debarment for its federal programs and will ensure that all parties with which it contracts for goods or services are eligible to participate in contracts involving the expenditures of federal program funding. Official Responsible – Peter Olson-Skog, the District’s Superintendent. Planned Completion Date – December 31, 2025. Disagreement With or Explanation of Finding – The District agrees with this finding. Plan to Monitor – Peter Olson-Skog, the District’s Superintendent, will ensure appropriate controls are in place to verify that any vendor with which the District contracts for federal program goods or services exceeding $25,000 is not listed as suspended or debarred on the federal Excluded Parties List System website.